U.S. Department 

of Transportation 

Federal Aviation 

Administration 

OCT Z 9 2014 

Amazon.com 

Legal Department, Paul Misener 

Re: Prime Air Exemption Petition 

440 Terry Ave. North 

Seattle, W A 981 09 

Dear Mr. Misener, 

In your petition for exemption dated July 10,2014 (Docket ID: FAA-2014-0474), you seek 

regulatory reliefto conduct civil operations of small unma1med aircraft systems (sUAS) on 

your own property for the purpose of conducting research and development for Amazon Prime 

Air. During our review, we have identified several areas where we would need additional 

information to complete our assessment of your petition. After considering the items below, 

please submit your materials with the docket number shown above to regulations.gov. We will 

continue review of your petition upon receiving the information requested. 

I. Section 333 ofthe 2012 FAA Modernization and Reform Act directs the Secretary 

of Transportation to determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of rulemaking required by 

section 332 of the Act, and furthermore, determine whether a certificate of waiver, 

certificate of authorization, or airw011hiness certifi cation under section 44704 of 

title 49, United States Code, is required for the operation of these unmanned aircraft 

systems. You are seeking an exemption for the purposes of experimentation, 

research and development, and conducting rapid prototyping of UAS. The aircraft 

to be operated for the purposes described in your petition may be issued special 

airworthiness certificates in the experimental category in accordance with the 

pertinent parts of 14 CFR §2 1.191. Given that the proposed operations can be 

conducted in accordance with existing regulations of §2 1.191 , please explain the 

particular circumstances regarding why an exemption would be an appropriate 

vehicle to permit those operations. 

2. To assist with the assessment of how your petition for exemption is in the public 

interest, please explain more fully the reasons why granting your request would be 

in the public interest; that is, how it would benefit the public as a whole. What data 

or analysis supports Amazon's position that aerial delivery is in the interest of the 

American public? Other examples of benefit to the public may include reductions 

in injuries or fatalities related to current hand delivery practices or reductions in 

environmental footprints. 

3. The petition seeks specific exemption from 14 CFR § 21.191 (a), 14 CFR § 

45.23(b), 14 CFR § 91.9(b), and 14 CFR § 9 1.203(a) and (b). However, footnote 1 

on page 3 of your petition requests, " relief from any associated or implementing 
2 

requirements of several related provisions that my otherwise be applicable,"' and 

lists ten additional regulations for which Amazon believes it may require 

exemption. However, the petition may not provide sufficient information to assess 

the regulations noted; including, for example, 14 CFR § 91 .1 51 or 14 CFR § 

91.405. In accordance with 14 CFR § 11.81(b), the petition must specify the 

section or sections of 14 CFR from which you seek exemption. Therefore, if you 

seek relief from other regulations in addition to 14 CFR § 21.1 91 (a), 14 CFR § 

45.23(b). 14 CFR § 91.9(b), and 14 CFR § 91.203(a) and (b), the petition should be 

amended accordingly. 

On September 25, 2014 the FAA released Public Guidance for Petitions for Exemption Filed 

under Section 333, which was not available to you at the time you submitted your petition. 

The guidance is available at, 

http://www. faa.gov/uas/legislative _programs/section _333/how _to_ file _a_petition/. 

Additionally, the FAA granted an exemption to Astraeus Aerial on September 25, 2014 which 

you may also wish to review. This grant of exemption is available at 

http://www. faa.gov/uas/legislative _programs/section_ 333/media/ Astraeus _ Aerial- 11 062.pdf. 

You may supplement your petition with additional information at any time. If you wish, 

please submit additional information to your specific docket at www.regulations.gov. 

Should you have questions, please contact the FAA Unmanned Aircraft Systems Integration 

Oftice at 202-267-8306. 

Sincerely/W Wctt-_ 

a ager 

S Integration Office, AFS-80